Question: We are currently blocking branch managers from seeing customer’s driver’s license on our core system due to their roles as lenders. Assuming we have adequate fair lending training and monitoring, is there any reason to block the driver’s license?
Answer: No, there is nothing to require the bank to block lenders from seeing images of driver’s licenses that are stored on your system. In fact, your CIP probably requires them to check some identification document such as a driver’s license.
What fair lending rules prohibit is using irrelevant information (e.g., gender/sex, race, etc.) that might be revealed by the picture and other information on a driver’s license in the bank’s credit decision. Because of this prohibition, regulators generally discourage retaining copies of picture IDs in loan files for loan types that do not require “government monitoring information,” such as automobile or other personal loans.
Appropriate fair lending training supported by monitoring can protect the bank from fair lending/discrimination issues, even when lenders are allowed to view stored images of driver’s licenses.